California, United States of America
The following excerpt is from People v. O'Brien, E074516 (Cal. App. 2021):
Leon controls here. Defendant's flight from the scene after shooting and killing Areyan was relevant to his consciousness of guilt for the first degree murder charge. The trial court therefore did not err in giving CALCRIM No. 372. (See Leon, supra, 61 Cal.4th at p. 607; see also People v. Henry (1937) 23 Cal.App.2d 155, 165 [jury instruction on flight proper because defendant's flight was relevant to defendant's consciousness of guilt].)
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